DHHS Transition to Subaccounts
Updated: December 9th, 2015
Why is DHHS making this change?
Funds for most awards are being drawn down in one lump sum, which makes it hard to account for cash drawn by the award level. The transition to subaccounts will allow each agency and the UW to account for and reconcile cash drawn against the FFR and SF-425 Cash Transaction Report by award more frequently and effectively.
When and how will this change take place?
New awards issued by NIH (Type 1, 2, 4, 6, 7, and 9) in Federal FY2014 (10/1/2013 – 9/30/2014) will be as a subaccount. All subsequent non-competing continuation awards will also be issued as a subaccount. Click here for a link to the description of application types.
Non-competing continuation awards issued on or after 10/1/2013, (Type 5 and 8), issued by NIH, will be phased into a subaccount during FY2015. These awards will be issued as Type 4.
- Campus should expect awards with single competitive segments (i.e. 5 year R01's) to be broken into two "competitive segments". The first segment will have an end date corresponding to the end of the current budget period and will be reported and drawn under the initial award reference number provided by NIH. Therefore, the FY2014 award becomes the final year of the first "competitive segment" and requires a final Federal Financial Report (FFR) to complete the funding for the award in the pooled account. The second segment, will be assigned a new award reference number by NIH, and will be reported and drawn under the subaccount. A final FFR will be required for the completion of the second segment at the end of the last budget period for the award. Here is a link to a visual interpretation of the process.
- Due to this change in procedure, RSP will need to set up a new Award ID (MSN number) and new project(s) for the second competitive segment. Closeout procedures will be initiated for the first competitive segment to complete the portion of the award in the pooled account.
How is carryover affected?
Original carryover terms will remain in place. Carryover funds will not be available in PMS until after the FFR is accepted.
- Automatic carryover: After the FFR is accepted, the unobligated balance reported on the FFR will be automatically carried over in PMS to the new document number (subaccount) and the RSP accountant will carry over the funds in SFS. If the unobligated balance is greater than 25% of the total amount authorized for the budget period, the GMO or GMS may request additional information before the funds are carried over in PMS.
- Carryover requiring prior approval: The UW will be required to submit a carryover request. A revised NOA will be issued if the carryover is approved.
If a project is overspent, can I transfer the overage to the new project ID that is created?
Yes. Per the NIH and DHHS grants policy statement, grantees can incur preaward costs before the beginning date of a non-competing continuation award beyond 90 days of the budget period. Click here for the NIH Grants Policy Statement.
What type of awards will be included with the transition?
All direct DHHS and flow-through awards will be affected. For awards that require annual reporting (awards not subject to SNAP), the impact will be minimal due to the annual reporting requirement that is already in place.
Could my award be affected?
The full list of potentially-affected awards or those for a specific PI or UDDS can be found at the following links:
Once the Notice of Award is issued and it is clear the award has transitioned to the new payment process, RSP will notify the PI and department, so work can begin on all transition activities.
Which agencies will be implementing this change?
All divisions under the Department of Health & Human Services (DHHS) are required to transition awards from the pooled account to subaccounts. NIH has delayed the transition for Type 5 (non-competing continuation) awards while other divisions have already implemented the transition. A list of DHHS agencies can be found here.
Are Final Progress Reports and Final Invention Statements required as part of the closeout for the first competitive segment?
What will RSP be doing to handle this change?
When NIH releases information about specific affected awards, RSP will contact the relevant departments and begin the necessary transition actions.
- The pre-award set up team will issue a new Award ID (MSN Number) and new Project ID(s) for affected awards. Departments will not need to take action on this item.
- The department will work with their RSP accountant to make the necessary changes to any existing subawards on the award. This requires department involvement.
- The RSP accountant assigned to the award will prepare a closeout analysis and work with the departmental contact to file the FFR for the period ending immediately prior to the switch. This requires department involvement.
Will new subawards need to be issued under the affected projects?
It will depend on the type of award (R01, P01, U01, etc) and will follow current procedures for creating a new subaward or modification to the existing. Additional information on the subawrd process can be found here. Please contact your RSP accountant for specific questions.
What needs to be done at the department level?
The department will need to work closely and quickly with the RSP accountant to facilitate the timely submission of the FFR for the period ending immediately prior to the switch.
The department will also need to facilitate the funding changes necessary to move to the new MSN and Project ID(s) established.
All payroll, purchasing, internal billing, etc., accounts connected to the affected projects, will need to be updated to the new projects at the department level. This includes, but may not be limited to the following:
|HRS/Payroll||MDS Accounts||Internal Billing|
|P-Card Funding Strings||On-going Blanket Orders||On-going Purchase Orders|
DHHS Subaccount Transition Timeline
October 1, 2015
- Type 5 & 8 (issued as Type 4) awards issued from DHHS using a subaccount.
- Departments may be able to make internal funding changes.
- 1st competitive segment ends.
- RSP accountant works with department on filing the FFR for 1st competitive segment.
- Award set-up is completed.
- Subaward modifications are processed.
- Carryover requests, if required, are submitted.
- Any remaining internal funding changes not previously completed are made.